The term whistleblowing refers to the voluntary disclosure made by an employee who, in the
performance of his or her duties, becomes aware of illegal, unethical, or fraudulent behaviors
carried out within an organization.
GIVA Group provides the opportunity to report such offenses through a dedicated platform that
guarantees confidentiality of the reporter's identity.
The objective of adopting this tool is to prevent non-compliance occurrences or wrongdoings
within the Group engaging employees, through an active and responsible participation, in the
fight against illegal behaviors. Responsible reporting, made in good faith and in the interest
of the common good, enable the Group to intercept in time, provide a remedy and prevent
illegitimate behaviors and illegal actions of corruption, fraud or other violations of the
Group’s Code of Conduct.
Reporting can be made by:
Reports shall relate to:
The following reports are excluded and therefore inadmissible:
GIVA Group has set up a dedicated reporting channel available to whistleblowers. The platform
uses a web-based solution that offers a customized portal for each Group company, thereby
ensuring compliance with all the necessary legal requirements, including those of personal data
processing and privacy regulation.
Reports should provide the following elements:
Click the button at the bottom of the page to access the reporting platform. Reports are
received by a team of experienced professionals external to the organization (outsourcer). The
outsourcer is committed to confidentially and bounded, in accordance with current legislation,
not to disclose the whistleblower’s identity without his/her consent. Any personal data is
processed in compliance with the current privacy regulation.
The whistleblowing team that manages the report will automatically issue an acknowledgement of
receipt to the whistleblower within seven days from the report submission.
In order to give proper follow-up to reports, the whistleblowing team carries out a first
assessment to verify that the basic requirements of the report are met to proceed in the process
(preliminary investigation). After the report is evaluated to be eligible for processing, the
whistleblowing team takes by all possible means the necessary investigative actions to further
follow up the report, including interviews and documents acquisition, always in accordance with
the principles of impartiality and confidentiality.
Upon completion of the investigation and, in any case, within 3 months from the date of the
acknowledgement of receipt, the whistleblowing team is committed to provide feedback to the
whistleblower, unless for well-grounded reasons, the deadline is extended to 6 months.
Information must be reported in good faith, providing full details. The information provided
will be treated according to the confidentiality criteria. The whistleblower who reports in good
faith is protected against any possible retaliation measure.
During the investigation activities, the reported person(s) may be involved or notified of the
ongoing procedure; nonetheless, under no circumstances, any proceedings will be initiated if not
in presence of rehearsed and concrete evidence of the contents reported.
It is the whistleblower’s responsibility to make reports in good faith and in accordance with
the stated intent of this procedure. Reports that are manifestly unfounded, opportunistic and/or
submitted for the sole purpose of harming the reported person(s), will not be considered and
will be liable to disciplinary sanctions and/or legal proceedings.